China’s 90% Rare Earth Hold and 2027 DFARS Ban Challenge Comstock’s Supply
China controls roughly 90% of global rare earth processing and will ban Chinese-origin materials in US defense systems from Jan. 1, 2027, risking supply for Comstock’s future projects. REalloys raised $50 million to build a $40 million facility producing 30 tonnes of dysprosium and 15 tonnes of terbium annually.
1. China’s Decades-Long Rare Earth Strategy
Over the past 30 years, China has built state-backed financing, predatory pricing and export controls to capture roughly 90% of global rare earth processing, covering mining through metal-making for military and civilian applications.
2. US DFARS 2027 Compliance Deadline
Effective January 1, 2027, updated DFARS rules will ban all Chinese-origin rare earth materials in American weapons systems at every production stage, forcing defense contractors to secure verified non-Chinese sources or face compliance checks and liability.
3. REalloys’ New Metallization Plant
REalloys completed a $50 million public offering and is investing $40 million to build North America’s largest heavy rare earth metallization facility, targeting annual output of 30 tonnes of dysprosium and 15 tonnes of terbium to supply critical defense-grade magnets.
4. Implications for Comstock Inc.
As a smaller rare earth explorer, Comstock must accelerate its development plans or partner with processors to meet the impending DFARS ban, or risk losing defense contracts if it cannot guarantee non-Chinese supply of heavy rare earths.